Burden Calculation Tables

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Overview

Respondent
Agency
Additional

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Sheet 1: Respondent

Burden item	(A) Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Applications	N/A									Labor Rates:
2. Survey and Studies	N/A									Management	147.40	These rates were updated 2/4/19 to match the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by occupational and industry group
3. Reporting requirements										Technical	117.92
A. Familiarization with the regulatory requirement	1	1	1	11	11	0.55	1.10	$1,440.91		Clerical	57.02
B. Required activities
Perf spec tests (certif) for CMS	16	1	16	1	16	0.80	1.60	$2,095.87
Repeat perf spec tests (certif) for CMS c,d	16	1	16	0	0	0	0	$0
Development of operating information e	160	1	160	1	160	8	16	$20,958.72
Annual update of operating information f	20	1	20	11	220	11	22	$28,818.24
Review of operating information with each operator g,h	8	2	16	11	176	8.8	17.6	$23,054.59
Initial control equipment inspection i	20	1	20	1	20	1	2	$2,619.84
Annual control equipment inspection i	20	1	20	11	220	11	22	$28,818.24
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write reports
Notification of intent to construct f	2	1	2	1	2	0.10	0.20	$261.98
Notification of anticipated commencement of construction g	2	1	2	1	2	0.10	0.20	$261.98
Notification of anticipated startup g	2	1	2	1	2	0.10	0.20	$261.98
Notification of actual startup g	2	1	2	1	2	0.10	0.20	$261.98
Notification of type(s) of waste to be combusted	2	1	2	1	2	0.10	0.20	$261.98
Notification of HMIWI capacity	2	1	2	1	2	0.10	0.20	$261.98
Notification of initial performance test h	2	1	2	1	2	0.10	0.20	$261.98
Notification of initial CMS demonstration	2	1	2	1	2	0.10	0.20	$261.98
Initial report for the site selection analysis j	460	1	460	1	460	23	46	$60,256.32
Waste management plan k	160	1	160	1	160	8	16	$20,958.72
Analysis and supporting documentation demonstrating conformance with EPA guidance and specifications for bag leak detection systems l	40	1	40	0.67	26.67	1.33	2.67	$3,493.12
Report of initial performance test m	8	1	8	1	8	0.40	0.80	$1,047.94
Report of initial CMS demonstration m	See 3B
Annual report
CMS emissions/operation parameters n	32	1	32	11	352	17.6	35.2	$46,109.18
Exceedances/ malfunctions/periods of which data not obtained q,p	48	1	48	2.2	105.6	5.28	10.56	$13,832.76
Results of performance tests conducted during the year q	40	1	40	11	440	22	44	$57,636.48
Report of no exceedances q,p	24	1	24	8.8	211.2	10.56	21.12	$27,665.51
Report of annual control equipment inspection	See 3B
Semiannual report of exceedances/ malfunctions/periods for which data not obtained q,p,r	48	1	48	2.2	105.6	5.28	10.56	$13,832.76
Subtotal for Reporting Requirements					3,114			$354,735
4. Recordkeeping requirements
A. Familiarize with regulatory requirement	See 3A
B. Plan activities	N/A
C. Implement activities	N/A
D. Develop record system	N/A
E. Time to enter information
Documentation produced as a result of sitting requirements	See 3E
Records of operators completing operator training requirements h	2	2	4	1	4	0.20	0.40	$523.97
Records of operators that have been qualified as HMIWI operators h	2	2	4	1	4	0.20	0.40	$523.97
Records of initial performance test	See 3E
Records of startup, shutdown, or malfunction	1.5	52	78	11	858	42.9	85.8	$112,391.14
Records of persons completing review of operating information h	2	2	4	11	44	2.2	4.4	$5,763.65
Records of process and control device operating parameters	1.5	52	78	11	858	42.90	85.8	$112,391.14
Records of CMS operation and maintenance g	0.03	365	9.13	11	100.38	5.02	10.04	$13,148.32
Records of exceedances/malfunctions/periods for which data not obtained	1.5	52	78	11	858	42.9	85.8	$112,391.14
Records of annual and any subsequent compliance tests	See 3E
Records of annual control equipment inspections	See 3B
Records of bag leak detection system alarms l	1.5	52	78	7.33	572	28.60	57.20	$74,927.42
F. Time to train personnel t	40	1	40	11	440	22	44	$57,636.48
G. Time for audits	N/A
Subtotal for Recordkeeping Requirements					4,299			$489,697
Total Labor Burden and Costs (rounded) u					7,410			$844,000
Capital and O&M Cost (rounded) u								$519,000		Hrs/resp	126
GRAND TOTAL (rounded) u								$1,360,000
Assumptions:
a We have assumed that the average number of sources that will be subject to the standard will be 11, including 10 existing respondents and one additional new source per year that will become subject to the rule over the three-year period of this ICR.
b This ICR uses the following labor rates: $147.40 per hour for Executive, Administrative, and Managerial labor; $117.92 per hour for Technical labor, and $57.02 per hour for Clerical labor. These rates are from the United States Department of Labor, Bureau of Labor Statistics, June 2018, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total Compensation.” The rates have been increased by 110% to account for the benefit packages available to those employed by private industry.
c We assume that performance specification to certify CMS is expected to take approximately 16 hours.
d We assume no failures of the initial CMS demonstrations; includes CO CEMS.
e We assume it will take 160 hrs to develop the operating information.
f We assume that it will take 20 hours to update the operating information each year.
g We assume that it will take 8 hours to review the operating information with each operator.
h We assume that it will take 2 operators per facility to enter information. Also assume there is no operator turnover at the affected facilities.
i We assume that annual control equipment inspection will occur for all sources.
j We assume that it will take 460 hours to develop the site selection analysis.
k We assume that it will take 160 hours to develop the waste management plan.
l We assume that it will take 40 hours to develop the bag leak detection system analysis and 1.5 hours to record bag leak detection system alarms. We assume the total number of sources will be evenly distributed among small, medium, and large sources and only new large and medium sources (i.e. two-thirds of the effected sources) will install baghouses.
m We assume that it will take 8 hours for each facility to review the report of the initial performance test for pollutants and fugitive ash.
n Person-hours per occurrence are assumed to be 32 hours.
o We have assume that it will take 48 hours and 24 hours per report per affected facility to report monitoring exceedances and no excess emissions, respectively. Because testing and monitoring requirements focus primarily on three pollutants (PM, CO, and HCl), assume three pollutants.
p Assume 20 percent of respondents report monitoring exceedances and 80 percent report no excess emissions.
q Assume 40 hours to review report of annual compliance test.
r Because the semiannual report coincides once each year with the annual report and both reports include information on exceedances, malfunctions, and periods for which data were not obtained, the frequency of the semiannual report is shown in the table as only once per year to avoid double-counting.
s We assume that this activity will be recorded daily.
t We assumed that it will take 40 hours once per year to train one person to perform the Method 9 and Method 22 tests. The labor requirements to train the personnel were estimated to be 8 hr/d for 5 d/yr.
uTotals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 2: Agency

Activity	(A) EPA Person hours per occurrence	(B) No. of occurrences per respondent per year	(C) Person hours per respondent per year (C=AxB)	(D) Respondents per year a	(E) Technical person- hours per year (E=CxD)	(F) Management person hours per year (Ex0.05)	(G) Clerical person hours per year (Ex0.1)	(H) Total Cost Per year b
1. Attend initial performance test c	32	1	32	0.08	2.56	0.13	0.26	$139.96		Labor Rates:
2. Repeat initial performance test										Management	65.71	These rates were updated 2/4/19 to match the rates from the Office of Personnel Management (OPM), 2018 General Schedule.
A. Retesting preparation d	12	1	12	0.2	2.4	0.12	0.24	$131.22		Technical	48.75
B. Attend retesting e	32	1	32	0.02	0.64	0.032	0.064	$34.99		Clerical	26.38
3. Litigation f	N/A
4. Excess emissions--enforcement activities g	32	1	32	0.02	0.64	0.032	0.064	$34.99
5. Report review
Review notification of intent to construct	2	1	2	1	2	0.1	0.2	$109.35
Review notification of anticipated commencement of construction	2	1	2	1	2	0.1	0.2	$109.35
Review notification of anticipated startup	2	1	2	1	2	0.1	0.2	$109.35
Review notification of actual startup	2	1	2	1	2	0.1	0.2	$109.35
Review notification of type(s) of waste to be combusted	2	1	2	1	2	0.1	0.2	$109.35
Review notification of HMIWI capacity	2	1	2	1	2	0.1	0.2	$109.35
Review notification of initial performance test	2	1	2	1	2	0.1	0.2	$109.35
Review notification of initial CMS demonstration	2	1	2	1	2	0.1	0.2	$109.35
Review notification addressing sitting requirements	24	1	24	1	24	1.2	2.4	$1,312.16
Review waste management plan	8	1	8	1	8	0.4	0.8	$437.39
Review analysis for bag leak detection systems h	8	1	8	0.67	5.33	0.27	0.53	$291.59
Review report of initial performance test i	54	1	54	1	54	2.7	5.4	$2,952.37
Review report of initial CMS demonstration	N/A
Review annual report
CMS emissions/operating parameters j	6	1	6	11	66	3.3	6.6	$3,608.45
Exceedances/malfunctions/periods for which data not obtained k	8	1	8	2.2	17.6	0.88	1.76	$962.25
Results of performance test conducted during the year l
PM, CO, HCl	18	1	18	11	198	9.9	19.8	$10,825.35
Fugitive ash emissions	6	1	6	11	66	3.3	6.6	$3,608.45
Report of no exceedances m	2	1	2	8.8	17.6	0.88	1.76	$962.25
Report of annual control equipment inspection n	4	1	4	11	44	2.2	4.4	$2,405.63
Review semiannual report of exceedances/ malfunctions/periods for which data not obtained k,o	8	1	8	2.2	17.6	0.88	1.76	$962.25
TOTAL (rounded) p					621			$29,500
Assumptions:
a We have assumed that the average number of sources that will be subject to the standard will be 11. There will be one additional new source per year that will become subject to the rule over the three-year period of this ICR.
b This cost is based on the following labor rates which incorporates a 1.6 benefits multiplication factor to account for government overhead expenses: Managerial rate of $65.71 (GS-13, Step 5, $41.07 + 60%), Technical rate of $48.75 (GS-12, Step 1, $30.47 + 60%), and Clerical rate of $26.38 (GS-6, Step 3, $16.49 + 60%). These rates are from the Office of Personnel Management (OPM) “2018 General Schedule” which excludes locality rates of pay.
c We assume EPA personnel attend 8 percent of the initial performance tests.
d We assume that 20 percent will fail the initial performance test, and will have to repeat the performance test.
e We assume 10 percent of initial performance re-tests are attended by EPA personnel.
f This ICR does not account for litigation costs.
g We assume 10 percent of the affected facilities are required to re-test as a result of excess emissions, and that EPA personnel attend 10 percent of these tests.
h We assume only new large and medium sources (i.e. two-thirds of the effected sources) will install baghouses.
i We assume 6 person-hours per report per pollutant. For the three new HMIWI in the three-year period, nine pollutants are required to be tested.
j We assume 1 person-hour per report per CMS. For HMIWI, assume each uses six CMS (flue gas temperature, secondary chamber temperature, charge weight, scrubber liquor pH, scrubber liquor flow, and scrubber energy input).
k We assume 20 percent of the affected facilities with recurrent burden will report monitoring exceedances.
l We assume 6 person-hours per report per pollutant. For annual tests, there are three pollutants (PM, CO, and HCl) for all HMIWI.
m We assume 80 percent of the affected facilities with recurrent burden will report no excess emissions.
n We assume it will take 4 hours to review the annual control equipment inspection report.
o Because the semiannual report coincides once each year with the annual report and both reports include information on exceedances, malfunctions, and periods for which data were not obtained, the frequency of semiannual report is shown in the table as only once per year to avoid double-counting.
p Totals have been rounded to 3 significant figures. Figures may not add exactly due to rounding.

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Sheet 3: Additional

Capital/Startup vs. Operation and Maintenance (O&M) Costs
(A)	(B)	(C)	(D)	(E)	(F)	(G)
Continuous Monitoring Device	Capital/Startup Cost for One Respondent	Number of New Respondents	Total Capital/Startup Cost, (B X C)	Annual O&M Costs for One Respondent	Number of Respondents with O&M	Total O&M, (E X F)
DIFF/WS	$1,233	1	$1,233	$4,733	11	$52,063
DIFF	$967	1	$967	$2,733	11	$30,063
WS	$1,233	1	$1,233	$1,133	11	$12,463
SNCR	$1,400	1	$1,400	$300	11	$3,300
CO CEMS	$17,500	1	$17,500	$25,100	11	$276,100
BLD	$1,033	1	$1,033	$1,267	11	$13,937
ACI	$0	1	$0	$3,367	11	$37,037
Testing	$67,458	1	$67,458	$0	11	$0
Filing Cabinets	$100	1	$100	$0	11	$0
Photocopying	$0	1	$0	$199	11	$2,189
Postage	$0	1	$0	$93	11	$1,023
TOTAL			$90,900			$428,000	$519,000
Number of Respondents
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents 1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	1	9	0	0	10
2	1	10	0	0	11
3	1	11	0	0	12
Average	1	10	0	0	11
Total Annual Responses
(A)	(B)	(C)	(D)	(E)
Information Collection Activity	Number of respondents	Number of responses	Number of respondents that keep records but do not submit reports	Total annual responses
				E = (B x C) + D
Notification of intent to construct	1	1	N/A	1
Notification of anticipated commencement of construction	1	1	N/A	1
Notification of anticipated startup	1	1	N/A	1
Notification of actual startup	1	1	N/A	1
Notification of type(s) of waste to be combusted	1	1	N/A	1
Notification of HMIWI capacity	1	1	N/A	1
Notification of initial performance test	1	1	N/A	1
Notification of initial CMS demonstration	1	1	N/A	1
Initial report for the site selection analysis	1	1	N/A	1
Waste management plan	1	1	N/A	1
Analysis and supporting documentation demonstrating conformance with EPA guidance and specifications for bag leak detection systems1	0.67	1	N/A	0.67
Report of initial performance test	1	1	N/A	1
Report of initial CMS demonstration	1	1	N/A	1
Annual report
CMS emissions and operating parameters	11	1	N/A	11
Exceedances, malfunctions, and periods for which data not obtained2	2.2	1	N/A	2.2
Results of performance tests conducted during the year	11	1	N/A	11
Report of no exceedances2	8.8	1	N/A	8.8
Report of annual control equipment inspection	11	1	N/A	11
Semiannual report of exceedances, malfunctions, and periods for which data not obtained 2	2.2	1	N/A	2.2
Total (rounded)				59
1 Assume the total number of sources will be evenly distributed among small, medium, and large sources and only new large and medium sources (i.e. two-thirds of the effected sources) will install baghouses.
2 Assume 20 percent of respondents report monitoring exceedances and 80 percent report no excess emissions.